DRC-2012-002145 - 0901a0688031ba3c

Gnerm/Fuek
DRC-2012-0021/|5
(IBRI Inc.
October 26,2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Director, Division of Radiation Control
Utah Department ofEnvironmental Quality
195 North 1950 West
P O Box 144850
Salt Lake City, UT 84114-4820
Re Response to Utah Division of Radiation Control ("DRC") letter of August 30, 2012
Report Justifying Additional Volume of Excavation for Claricone
Dear Mr Lundberg
This letter responds to Utah Division of Radiation Control's ("DRC's") above-named letter dated
August 30, 2012, and Item 4 of DRC's Stormwater Inspection Report and request for Additional
Information dated September 7, 2012, regarding a proposal for additional soil excavation in the area of
the Apnl 2012 Clancone spill at Energy Fuels Resources (USA) Inc's ("EFRI's") White Mesa Mill
Background
EFRI notified DRC by telephone on April 12, 2012 of a spill of solutions from the Claricone The
telephone notification was followed by a written Notice and Response Plan on May 4, 2012, as required
by the Mill's Spill Prevention, Control, and Countermeasures Plan and UAC 19-5-114
DRC responded to the Notice and response Plan on August 30, 2012, as part of the summary report of
DRC's June 21, 2012 stormwater inspection at the Mill DRC's letter of August 30, 2012 stated m item
4
"Based on DRC review of the DUSA May 4, 2012 letter "Response to Claricone Solution Spill" it was
noted that confirmation soil sampling was not conducted to ensure that all contaminated soil had been
removed Excavation of contaminated material was based on visual examination and gamma surveying
(microR meter) only "
Item 4 offered DUSA [currently named EFRI] the choice of submitting to DRC either
A A work plan for the collection of confirmation soil samples to be collected and analyzed
for appropriate radiological parameters and total uranium within 45 days from DUSA
receipt of this letter The work plan will detail the techniques to be used for sample
collection, number and locations of samples to be collected, methods to be used for soils
analysis, and will propose confirmation sample concentration thresholds to be used for
the evaluation DUSA will propose applicable concentration standards to be used for
radiological parameters (per applicable guidance/regulations), and will propose a study
Energy Fuels Resources (USA) Inc 225 Union Boulevard, Suite 600
Lakewood, CO 80228 Phone [phone]
Letter to Rusty Limdberg
October 26, 2012
Page 2 of 10
evaluation to determine an appropriate background concentration for total uranium
within the restricted area of the Mill The total uranium soil concentration threshold to
be used for confirmation samples will be based on 2 times the average measured
background concentrations for total uranium as determined through the work plan study,
or
B A conservative basis for a larger three dimensional area of potentially contaminated soil
due to the claricone solution spill, in lieu of confirmation soil sampling, which will
include a calculated soil excavation volume (beyond the previous excavated soil volume)
DUSA will provide a Report which describes the justification for the calculated soil
volume and includes a surface map of the Mill and cross sections clearly depicting the
ultimate area of soil for excavation, removal and disposal (at site closure) DUSA will
provide a surety estimate, for Director review and approval, which includes line items for
all work associated with excavation, removal and disposal of the proposed soil volume
The Report and Surety Estimate will be submitted within 45 days from DUSA receipt of
this letter
During telephone discussions between DRC and EFRI during August 2012, and in EFRI's response letter
dated September 7, 2012, EFRI agreed to provide a Report including a basis for a larger excavation
volume, as descnbed below
"EFR proposes to produce a conservative estimate of potentially contaminated soil resulting from the
Clancone spill, and calculation of additional soil excavation volume to be removed at reclamation,
consistent with Item B, above EFR will provide a Report which descnbes the justification for the
calculated soil volume and includes a surface map of the Mill and cross sections clearly depictmg the
ultimate area of soil for excavation, removal and disposal (at site closure) EFR will provide a surety
estimate, for review and approval by the Director of the Division of Radiation Control, which mcludes
line Items for all work associated with excavation, removal and disposal of the proposed soil volume As
agreed to in our telephone conversation of August 28,2012, and confirmed by DRC's letter of August 30,
2012, EFR will provide the required report by October 26,2012 "
DRC approved EFRI's response m a letter dated August 30, 2012, provided in Attachment 1 The
remainder of this letter constitutes the Report described above
Letter to Rusty Lundberg
October 26, 2012
Page 3 of 10
SUMMARY REPORT
PROPOSED EXCAVATION AT MILL DECOMISSIONBVG
TO REMOVE POTENTIALLY CONTAMINATED ADDITIONAL SOIL
Description of Previous Excavation
A sketch of the White Mesa Mill process area indicatmg the approximate location and boundanes of the
Apnl 2012 Clancone excavation are provided in Attachment 2A Contaminated equipment, process
material, and soil was disposed in Cell 3
As described in the May 4, 2012 Notice and Plan, after removal of Claricone equipment, associated
structures, and the pumpable portion of the spilled solutions, the April 2012 Clancone excavation was
conducted as follows
The extent of soil removal addressed both chemical and radiological contamination All soils visibly
wet, stamed or discolored were excavated until uncontaminated dry background soils remained
The bottom and sides of the excavation were scanned by microR meter (measuring residual gamma
contammation) When the bottom or sides of the excavation indicate gamma levels greater than
background levels, the excavation was resumed, additional contaminated soil was removed, and the
bottom and sides of the excavation were re-scanned until all surfaces result in gamma levels less than or
equal to cleanup background (Cleanup background was defined as two times the average of four
measured background readings taken as described in Attachment 3 This approach accounted for the
contribution to background of gamma radiation from other nearby process equipment such as the
clarifier, thickener, and CCD impounds) When the bottom and sides of the excavation indicated
gamma levels of less than cleanup background as defined above, the excavation was considered
complete, and the area was prepared for backfill and re-grading
The May 4, 2012 Notice and Plan indicated that the total estimated volume removed from the excavation
was 1,134 cubic yards Based on final drawings and the volume of clean replacement soil used to backfill
the excavation, the total estimated volume of material actually removed was 4,600 cubic yards as
indicated in the figure in Attachment 2B The excavated volume of 4,600 cubic yards was subsequently
replaced with clean backfill
Conservative Basis for Larger Excavation Volume
The previously completed excavation attempted to locate and remove all contaminants discharged during
the Clancone spill by
1 Removal of all matenal visibly stained or wet Any soil apparently wet, containing visible spilled
material (crystals, precipitates, lumps), discolored, or having an otherwise non-typical
appearance, was excavated
2 Removal of radionuclides based on delmeation by gamma detection A gamma survey was
considered to be suitable because the spilled Clancone solutions contamed appreciable
concentrations of gamma-emitting radionuclides
3 Assumption that chemical constituents would be removed by removal of detectable radionuclides
The Claricone contained saturated solutions undergoing solid/liquid separation for recovery of
solid constituents, and did not contam gaseous or volatile constituents that would not be detected
Letter to Rusty Limdberg
October 26, 2012
Page 4 of 10
by either visual examination or radiological scanning Although the transport of chemical
constituents in environmental media may differ substantially from the transport of those
constituents identifiable by radiological scanning, it was assumed that chemical constituents
would be captured because the very short duration between the Clancone spill and the completion
of the removal action (15 days total) would not allow for any appreciable migration of chemical
constituents
The areal footprint of the excavation was determined by assuming the entu-e area up to adjacent
equipment in every direction around the 29 V2 foot diameter Clancone would be removed As indicated
m Attachment 2B, an area approximately 56 feet in its narrowest dimension and 80 feet m its longest
dimension was excavated
After removal of all the visibly contaminated soil, the depth of the excavation was determined by locating
the deepest depth below ground surface at which any radiological (gamma) detection exceeded the
background determined as described above The entire footrpnnt was then excavated to that maximum
depth The excavation was completed to a depth of 25 feet below ground surface ("bgs") across the entire
footprint
Nonetheless, durmg discussions with DRC in August 2012, DRC indicated concem that due to the lack of
confirmatory radiological sampling, the gamma survey method may not have bounded the entire extent of
the contamination Although EFRI believes that the contamination has been removed in its entirety, EFRI
agreed to assess an additional area and depth that could be excavated at the time of Mill
decommissioning, as an extra measure of conservatism
Justification for Calculated Soil Volume
Although EFRI believes the contamination has been removed, EFRI has agreed to removal of an
additional soil volume as indicated in Attachment 2B EFRI proposes to excavate an additional two feet
in every direction (around the perimeter and below the bottom of the existing excavation) The excavation
of additional two feet in each direction will result in an estimated 1,000 cubic yards of potentially
contaminated soil to be excavated
For the purposes of developing a conservative estimate of additional cost for the reclamation surety, EFRI
has tripled the excavation volume from 1,000 to 3,000 cubic yards for the cost calculations for the reasons
discussed herein
The proposed excavation will require the removal of the 4,600 cubic yards of clean backfill in order to
reach the additional two feet of potentially contaminated soil around the perimeter and bottom of the
former excavation The removed 4,600 cubic yards would theoretically be set aside for reuse in refilling
the excavation, and would not need to be placed in the tailings area
For conservatism, the cost estimate has assumed that up to 2,000 cubic yards of the 4,600 removed clean
fill could potentially be contaminated and would also be disposed in the tailings system rather than
replaced in the excavation as backfill Therefore, the volume estimate of disposed contamianted soils has
been tnpled from 1,000 to 3,000 cubic yards
Letter to Rusty Limdberg
October 26, 2012
Page 5 of 10
Surface Map and Cross Sections
As mentioned above, a surface map of the Mill indicating the area of the proposed additional Claricone
excavation is provided in Attachment 2A A detail of the proposed excavation area is provided in
Attachment 2B
The removal resulted m an excavation with a flat floor at 25 feet bgs and vertical sidewalls throughout the
"hole" Based on information from well logs at the nearest wells (MW-27, TWN-2, and TW4-25), the top
of the low permeability Mancos shale m the vicinity of the excavation varies from less than 5 feet to
approximately 9 or more feet The top of the lower permeability Dakota sandstone varies from
approximately 16 feet to over 27 feet
EFRI agrees to perform the additional excavation at the time of decommissionmg consistent with the
previously completed excavation, that is, to excavate a vertical-walled flat bottomed excavation 2 feet
wider m each dimension than the completed and backfilled excavation Excavated soil would be disposed
in the tailings cells
Surety Estimate
A revised surety estimate including line items for work associated with excavation, removal and disposal
of the additional volume of soil to be removed is provided in Attachment 3 As discussed above, for
conservatism, the revised surety estimate assumes tnple the 1,000 cubic yard volume indicated in the
drawings, that is it assumes a 3,000 cubic yard additional excavation
The assumption of an additional 3,000 cubic yard excavation resulted in an additional line item under the
Mill Decommissioning costs entitled "Clancone Contaminated Soil Disposal" of $5,652 This addition to
the surety estimate results m a revised total surety estimate of $20,308,145
Please contact me if you have any questions or require any further information
Yours very truly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance
cc David C Frydenlund
Daniel C Hillsten
Harold R Roberts
David E Turk
Kathy A Weinel
Attachments
ATTACHMENT 1
GARY R HERBERT
Govenioi
GREG BELL
Lieutenant Governoi
{^^t,Dc^,^Ar-i6\Aj^jM, err
Department of
Environmental Quality
Amanda Smith
Executive Diiector
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Diiector
RECEIVED
SEP 0 5 2012 August 30,2012
Jo Ann Tischler '
Director, Compliance
Energy Fuels Resources (USA) Inc
22S Union Boulevard, Suite 600
Lakewood, CO 80228
Subject. Energy Fuels Resources (USA), Inc Request for Extension of Time DRC
Approval
Dear Ms Tischler.
This IS in response to your e-mail dated August 29,2012 which requests an extension of time for
Energy Fuels Resources (USA) Inc ("EFR") to respond to Confirmatory Action Item No 4 of the
August 8, 2012 DRC Request for Information, Notice of Enforcement Discretion and
Confirmatoiy Actions Letter ("CAL") regarding the 2012 DRC inspection at the White Mesa
Uranium Mill (CAL received by EFR on August 10,2012) Specifically, you request an extension
of time for the due date, from September 24,2012 (45 days from EFR receipt of the Letter) to
October 27,2012 (32 day extension) DRC notes that October 27,2012 is a Saturday, therefore
the extension date was altered to business day, Fnday, October 26,2012
Per your e-mail request the additional time is needed to prepare the report items required by the
CAL item 4, specifically
• a conservative basis for a larger three dimensional area of potentially contaminated soil
due to the clancone solution spill, in lieu of confirmation soil sampling, which will include
a calculated soil excavation volume (beyond the previous excavated soil volume),
• justification for the calculated soil volume,
• a surface mq) of the Mill and cross sections clearly depicting the ultimate area of soil for
excavation, removal and disposal, and
/ • a surety estimate, for Director review and approval, which includes line items for all work
associated with excavation, removal and disposal of the proposed soil volume
Based on review of your request, the extension of time to submit the report is approved Please
ensure that all items are subnutted on or before October 26,2012.
195 North 1950 West • Salt Lake City. UT
Mailing Address P O Box 144850 • Salt Lake Cily, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
Jo Ann Tischler
Page 2
If you have any questions regarding this letter please contact Tom Rushing at [phone]
Sincerely,
Rusty Lundberg, Director
RLTRtr
F \DUSA\Storm Water Managenient\2012 SW InspectionVCAL Extension Approval\2012 SW CAL Extension of Time Approval docx
Attachment 2A
Mill Process Area and Location of Former Claricone Excavation
mm
Legend
Approximate
boundary of
former
Claricone
excavation
ATTACHMENT 2B
ATTACHMENT 2A
NOTES
• 4 600 cuyds of soil was removed at the time ot ttie
removal of the Claricone
• The excavation proposed at the time of mill decomission
totals 1 000 cuyds
• The proposed area includes a two foot extension to the
tx^undary of previously excavated soils 16 8
SCALE IN FEET
Mill Decommissioning
Planned Soils Removal
in Clancone Area
|°°" 10/V12 1°"^
ATTACHMENT 2C
ATTACHMENT 2C
CROSS SECTIONAL DIMENSIONS OF CLARICONE EXCAVATION
The April 2012 excavation of contaminated and additional soil associated with the Claricone spill
consisted of an excavation footprint as shown m the plan drawing in Attachment 28, with
• Excavation to a flat bottom depth of 25 feet below ground surface ("bgs ")all the way across the
blue hatched area of excavation, and
• Approximately vertical side walls around the entire penmeter as indicated by the blue hatched
area in Attachment 28
The proposed excavation of potentially-contaminated additional soil at Mill decommissioning would
consist of
• Excavation to a flat bottom depth of an additional 2 feet, that is 27 feet bgs, all the way across
the area of excavation, and
• A perimeter of an additional two feet width as indicated by the red hatched area m Attachment
28, with approximately vertical side walls
ATTACHMENT 3
WHITE IVIESA MILL RECLAMATION COST ESTIMATE
October 2012
Revision 4.11
Mobilization $437,800
Office Facilities $58,500
Mill Decommissioning $2,138,123
CelM $1,776,448
Cell 2 $1,803,668
Cells $2,067,848
Cell 4A $1,435,844
Cell 4B $1,465,011
Management Support $2,297,613
Miscellaneous $869,063
Subtotal Direct Costs $14,339,919
Profit Allowance 10 00% $1,433,992
Contingency 15 00% $2,150,988
Licensing & Bonding 2 00% $286,798
UDEQ Contract Administration 4 00% $573,597
Engineenng Design Review 2 25% $322,648
Contractors Equipment Floater $82,250
Automobile and General Liability Insurance $284,600
Long Term Care Fund $833,353
Total Reclamation $20,308,145
Revised Bond Amount $20,308,145
10/25/2012 -10 10 AM - WMM Rec Plan Est October 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Mill Building Demolition
MILL DECOMMISSIONING
Resource Description Units Cost/Unit Task Units Task Cost
hrs $15 03 640 $9,618
hrs $15 25 320 $4,879
hrs $1 35 960 $1,296
hrs $97 66 640 $62,501
hrs $21 51 640 $13,768
hrs $137 94 160 $22,071
hrs $25 75 160 K120
hrs $133 91 160 $21,425
hrs $27 26 160 $4,362
hrs $154 00 160 $24,639
hrs $27 26 160 $4,362
hrs $97 93 160 $15,668
hrs $28 41 160 $4,545
hrs $62 40 80 $4,992
hrs $28 41 80 $2,273
hrs $19 10 1.360 $25,974
sf $3 30 37,500 $123,750
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Mill Building Demolition $350,244
Ore Feed Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Total Ore Feed Demolition
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $17 21 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $1910 112 $2,139
$19,095
SX Building Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 320 $4,809
hrs $15 25 160 $2,439
hrs $1 35 480 $648
hrs $97 66 320 $31,251
hrs $21 51 320 $6,884
hrs $137 94 80 $11,035
hrs $25 75 80 $2,060
hrs $133 91 80 $10,713
hrs $27 26 80 $2,181
hrs $154 00 80 $12,320
hrs $27 26 80 $2,181
hrs $97 93 0 $0
hrs $28 41 0 $0
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $1910 560 $10,695
sf $3 30 55,970 $184,701
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total SX Building Demolition $281,917
10/25/2012 -10 17 AI^WMM Rec Plan Est Octot>er 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
CCD Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total CCD Circuit Removal
hrs $15 03 120 $1,803
hrs $15 25 60 $915
hrs $1 35 180 $243
hrs $97 66 120 $11,719
hrs $21 51 120 $2,582
hrs $137 94 30 $4,138
hrs $17 21 30 $516
hrs $133 91 30 $4,017
hrs $20 65 30 $620
hrs $154 00 30 $4,620
hrs $20 65 30 $620
hrs $97 93 30 $2,938
hrs $15 76 30 $473
hrs $62 40 15 $936
hrs $15 76 15 $236
hrs $1910 255 $4,870
sf $3 30 15,000 $49,500
$90,746
Sample Plant Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Sample Plant Removal
Temporary Storage Building Removal
Resource Description
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 32 $3,125
hrs $21 51 32 $688
hrs $137 94 8 $1,104
hrs $17 21 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $1910 56 $1,070
sf $3 30 4.200 $13,860
Units Cost/Unit Task Units
$23,408
Task Cost
hrs $15 25 8 $122
hrs $1 35 8 $11
hrs $97 66 2 $195
hrs $21 51 2 $43
hrs $137 94 2 $276
hrs $25 75 2 $52
hrs $19 10 4 $76
sf $3 30 600 $1,980
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Temporary Storage Building Removal $2,755
10/25/2012 -1017 fiM-VmtA Rec Plan Est Octot>er 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Truck Shop Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Truck Shop Removal
Boiler Demolition
Resource Description
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 24 $2,344
hrs $21 51 24 $516
hrs $137 94 8 $1,104
hrs $17 21 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 48 $917
sf $3 30 4,200 $13,860
Units Cost/Unit Task Units
$22,301
Task Cost
hrs $15 03 160 $2,405
hrs $15 25 80 $1,220
hrs $1 35 240 $324
hrs $97 66 160 $15,625
hrs $21 51 160 $3,442
hrs $137 94 40 $5,518
hrs $17 21 40 $689
hrs $133 91 40 $5,356
hrs $20 65 40 $826
hrs $154 00 40 $6,160
hrs $20 65 40 $826
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $1910 280 $5,348
sf $3 30 2,900 $9,570
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Boiler Demolition $57,308
Vanadium Oxidation Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Vanadium Oxidation Circuit Removal
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $17 21 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $1910 112 $2,139
sf $3 30 1,200 $3,960
$23,055
10/25/2012 -10 17 AM-WMM Rec Plan Est October 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Mam Shop/Warehouse Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Mam Shop/Warehouse Demolition
hrs $15 03 128 $1,924
hrs $15 25 64 $976
hrs $1 35 192 $259
hrs $97 66 128 $12,500
hrs $21 51 128 $2,754
hrs $137 94 32 $4,414
hrs $17 21 32 $551
hrs $133 91 32 $4,285
hrs $20 65 32 $661
hrs $154 00 32 $4,928
hrs $20 65 32 $661
hrs $1910 224 $4,278
sf $3 30 19,300 $63,690
$101,880
Decon Pads (2) Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Decon Pads (2) Demolition
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $17 21 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $19 10 112 $2,139
sf $3 30 1,350 $4,455
$23,550
Office Building Demolition
Resource Description Units Cost/Unit Task Units Task Cost
hrs $15 03 96 $1,443
hrs $15 25 48 $732
hrs $1 35 144 $194
hrs $97 66 96 $9,375
hrs $21 51 96 $2,065
hrs $137 94 24 $3,311
hrs $17 21 24 $413
hrs $133 91 24 $3,214
hrs $20 65 24 $496
hrs $154 00 24 $3,696
hrs $20 65 24 $496
hrs $1910 168 $3,209
sf $1 25 12,100 $15,125
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Office Building Demolition $43,768
10/25/2012 -1017 AM-WMM Rec Plan Est Otitsjber 2012 Rev 411
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Septic Tanks and Dram Fields
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Total Septic Tanks and Dram Fields
hrs $15 03 0 $0
hrs $15 25 16 $244
hrs $1 35 32 $43
hrs $97 66 16 $1,563
hrs $21 51 16 $344
hrs $137 94 8 $1,104
hrs $17 21 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 0 $0
hrs $20 65 0 $0
hrs $1910 32 $611
$5,283
Misc Tankage & Spare Parts Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 48 $721
hrs $15 25 24 $366
hrs $1 35 72 $97
hrs $97 66 48 $4,688
hrs $21 51 48 $1,033
hrs $137 94 12 $1,655
hrs $17 21 12 $207
hrs $133 91 12 $1,607
hrs $20 65 12 $248
hrs $154 00 12 $1,848
hrs $20 65 12 $248
hrs $19 10 84 $1,604
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Total Misc Tankage & Spare Parts Removal $14,321
Alternate Feed Circuit and Reagent Storage Building
Resource Description Units Cost/Unit Task Units Task Cost
hrs $15 03 50 $751
hrs $15 25 50 $762
hrs $1 35 96 $130
hrs $97 66 50 $4,883
hrs $21 51 50 $1,076
hrs $137 94 34 $4,690
hrs $17 21 34 $585
hrs $133 91 34 $4,553
hrs $20 65 34 $702
hrs $154 00 52 $8,008
hrs $20 65 52 $1,074
hrs $1910 170 $3,247
sf $3 30 3,500 $11,550
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Alternate Feed Circuit and Reagent Storage Building $42,011
10/25/2012 -1017 AM-WMM Rec Plan Est Octot>er 2012 Rev 4 11 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Mill Yard Decontamination
Resource Description Units Cost/Unit Task Units Task Cost
hrs $215 65 274 $59,087
hrs $27 26 274 $7,470
hrs $137 94 68 $9,380
hrs $25 75 68 $1,751
hrs $98 69 68 $6,711
hrs $25 75 68 $1,751
hrs $83 49 68 $5,677
hrs $25 75 68 $1,751
hrs $115 79 68 $7,874
hrs $23 48 68 $1,597
hrs $73 28 68 $4,983
hrs $27 26 68 $1,854
hrs $1910 614 $11,727
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Mill Yard Decontamination*
Ore Storage Pad Decontamination
Resource Descnption
$121,613
* Includes Ammonimum Sulfate Storage Tank contamination
Units Cost/Unit Task Units Task Cost
hrs $215 65 189 $40,757
hrs $19 31 189 $3,649
hrs $137 94 48 $6,621
hrs $17 21 48 $826
hrs $98 69 48 $4,737
hrs $20 65 48 $991
hrs $83 49 48 $4,008
hrs $20 65 48 $991
hrs $115 79 48 $5,558
hrs $1816 48 $872
hrs $73 28 48 $3,517
hrs $20 62 48 $990
hrs $1910 429 $8,193
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Ore Storage Pad Decontamination $81,712
Equipment Storage Area Cleanup
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Waterwagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Equipment Storage Area Cleanup
hrs $215 65 68 $14,664
hrs $19 31 68 $1,313
hrs $137 94 17 $2,345
hrs $17 21 17 $293
hrs $98 69 17 $1,678
hrs $20 65 17 $351
hrs $83 49 17 $1,419
hrs $20 65 17 $351
hrs $115 79 17 $1,968
hrs $1816 17 $309
hrs $73 28 17 $1,246
hrs $20 62 17 $351
hrs $19 10 153 $2,922
$29,210
10/25/2012 -1017 AM-WMM Rec Plan Est Octot)er 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa MUl
MILL DECOMMISSIONING
Revegetate Mill Yard & Ore Pad
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Seed MIX
Equipment Maintenance (Butler)
Total Revegetate Mill Yard & Ore Pad
Total Demolition and Decontamination
hrs $215 65 174 $37,523
hrs $19 31 174 $3,360
hrs $137 94 0 $0
hrs $17 21 0 $0
hrs $98 69 33 $3,257
hrs $20 65 33 $682
hrs $83 49 33 $2,755
hrs $20 65 33 $682
hrs $115 79 0 $0
hrs $1816 0 $0
hrs $73 28 33 $2,418
hrs $20 62 33 $681
Acre $322 50 50 $16,125
hrs $1910 273 $5,214
$72,695
I $1.406,87ll
CLEANUP OF WINDBLOWN CONTAMINATION
Scoping Survey
Resource Description Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 100 $5,000
Survey Crew hrs $14 46 752 $10,877
Sample Crew hrs $14 46 1,312 $18,977
Total Scoping Survey $34,854
Characterization Survey
Resource Description Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 472 $23,600
Sample Crew hrs $14 46 1,136 $16,431
Total Characterization Survey $40,031
Final Status Survey
Resource Description Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 300 $15,000
Sample Crew hrs $14 46 3,552 $51,377
Total Final Status Survey $66,377
10/25/2012 -10 17 AM-WMM Rec Plan Est October 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Windblown Cleanup
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Soil Samples
Survey Crew
Sample Crew
Equipment Maintenance (Butler)
Total Windblown Cleanup
Quality Control
Resource Descnption
hrs $215 65 680 $146,640
hrs $27 26 680 $18,538
hrs $98 69 170 $16,777
hrs $25 75 170 $4,378
hrs $83 49 170 $14,194
hrs $25 75 170 $4,378
hrs $73 28 170 $12,457
hrs $27 26 170 $4,634
each $50 00 500 $25,000
hrs $14 46 163 $2,358
hrs $14 46 83 $1,201
hrs $1910 1,190 $22,728
Units Cost/Unit
$62 oof
Task Units
$273,282
Task Cost
Quality Control Contractor
Total Quality Control
Total Cleanup Windblown Contamination
hrs 2,080 $128,960
$128,960
I $543,5031
Conventional Ore Disposal
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $97 66 639 $62,374
hrs $21 51 639 $13,740
hrs $137 94 213 $29,368
hrs $25 75 213 $5,482
hrs $115 79 213 $24,653
hrs $23 48 213 $5,000
hrs $73 28 25 $1,832
hrs $27 26 25 $682
hrs $1910 1,089 $20,808
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Conventional Ore Disposal
Total Quantity
I $163.939]
125,185 Cubic Yards*
196 Cubic Yards per Truck per hour
639 Truck Hours
* 169,000 tons maximum projected thru 2012 to March 2013
Loose (in-truck) matenal unit weight assumed as 100 Ib/cubic foot
Clancone Contaminated Soil Disposal
Resource Descnption
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Units Cost/Unit Task Units Task Cost
hrs $97 66 15 $1,495
hrs $21 51 15 $329
hrs $137 94 5 $704
hrs $25 75 5 $131
hrs $115 79 5 $591
hrs $23 48 5 $120
hrs $73 28 15 $1,099
hrs $27 26 15 $409
hrs $19 10 41 $774
Total Clancone Contaminated Soil Disposal
10/25/2012 -1017 AM-WMM Rec Plan Est Otittiber 2012 Rev 4 11
$5.652|
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Total Quantity 3,000 Cubic Yards*
196 Cubic Yards per Truck per hour
15 Truck Hours
*Use 3 times estimated volume
Loose (in-truck) matenal unit weight assumed as 100 Ib/cubic foot
Denison Mines (USA) Corp
10/25/2012-1017 AM-WMM Rec Plan Est October 2012 Rev 4 11 While Mesa Mill
MILL DECOMMISSIONING
Attemate Feed Disposal
Cabot and FMRI Material
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $97 66 33 $3,178
hrs $21 51 33 $700
hrs $137 94 11 $1,496
hrs $25 75 11 $279
hrs $115 79 11 $1,256
hrs $23 48 11 $255
hrs $73 28 6 $440
hrs $27 26 6 $164
hrs $1910 60 $1,150
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Cabot & FMRI Matenal $8,919
Total Quantity 6,379 Cubic Yards* (projected to 03/01/2013)
196 Cubic Yards per Truck per hour
33 Truck Hours
includes Cabot and FMRI
Cameco Barrels and Honeywell Barrels
Resource Descnption Units Cost/Unit Task Units Task Cost
Equipment Operators hrs $21 51 70 $1,510
Flat Bed Trailer and Tractor* hrs $55 00 70 $3,861
Fork Lift (2) hrs $18 00 140 $2,527
Equipment Maintenance (Butler) hrs $1910 70 $1,341
Total Cameco and Honeywell Barrels
* includes operator
$9,240
7,020 Ban-els
40 Barrels per load
0 4 Hours per load
70 Truck Hours
(projected to 03/01/2013)
Tons lbs per ban-el No Drums
Sub-Total Alternate Feed Disposal
CaF2 979 727 2,692
Calcined 435 320 2.719
Regen 31 406 153
KF 224 309 1.450
UF4 2 547 7
1,671 7.020
TOTAL MILL DECOMMISSIONING i $2,138,123|
WMM ALTERNATE FEED Ending Inventory, tons & barrels
Projection to March 2013
10/25/2012 -1017 AM-WMM Rec Plan Est October 2012 Rev 4 11
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Cabot
Fansteel/FMRI
Prior Year
Ending
Baiance
7.753
7,753
2012 YTD
Received
Processed
2012
358
Proiected
deiiveries iess
processing to
March 2013
500
358
Ending
iWatenat
Baiance
tons
858
7.753
8,611
CaF2- Honeywell
Calcined Product- Cameco
KF Product- Cameco
Regen Product- Cameco
UF4 Matenal- Cameco
tons
1,502
3,935
1.690
631
2
tons tons tons tons
125
34
148 (500)
(3,500)
(1,500)
(600)
979
435
224
31
2
7,760 159 148 1,671
10/25/2012 -10 17 AM-WMM Rec Plan Est October 2012 Rev 411
Denison Mines (USA) Corp
White Mesa Mill
Env
o
Depart
ironme
Amanda Smith
Executive Director
DTVISION OF RADIATION CONTROL
Rusty Lundberg
Director
ment of
ntal Quality
State of Utah
GARY R, HERBERT
Govemor
GREGORY BELL
Lieutenant Governor
November 15,2072
CERTIFIED MAIL
(RETURN RECEIPT REQUESTED)
David C. Frydenlund
Sr. Vice President Regulatory Affairs and General Counsel
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject:
Dear Mr. Frydenlund,
The DRC received your Response on October 29,
general conformance with the agreement detailed
the following comments:
Compliance: Sulfuric Acid Solution Release of April 12,2012; Review of Response
Dated October 26,2012 to Division of Radiation Control (DRC) Letter of August 30,
2012; Report Justiffing Additional Volume of Excavation at Former Claricone Site
(Response); Radioactive Materials License Number UT1900479 (RML): Request for
Information
2012. DRC staff reviewed the Response for
in your letter dated September 7,2012, and has
l While the plan concept looks appropriate, the map provides little detail to assure that
excavation occurs where intended. Decommissioning activities will likely result in
removal of structures and other prominent landmarks prior to performing the excavation.
To correct this situation, please provide either coordinates or a boundary description for
the proposed excavation site. Tie the coordinates or boundary to known USGS survey
monumentation.
2. Decommissioning activities near the excavation site will likely result in disturbance of the
ground surface. To assure that the excavation reaches the proper depth, please provide the
elevation above mean sea level for the excavation floor. Tie this elevation to USGS
monumentation.
195 North 1950 West . Salt take City, UT
Mailing Address: P.O. Box 144850 . Salt lake City, UT 841 l4-4850
Telephone [phone] . Fax [phone] . T D.D [phone]
www.deq.ulah.gov
Printed on I00% recycled paper
David C. Frydenlund
November 15,2012
Page2
3. The portion of the Response devoted to justifying the quantity of earth to be moved did not
consider the possibility that workers may need to follow contamination outside the
intended limits of excavation. Please adjust the Response to reflect this consideration. If
necessary, please adjust the volume of new fill required.
Please provide the requested information within 30 calendar days of receipt of this letter. If you
have any questionS or comments, please contact Russ Topham at [phone]'
Sincerely,
T!4fuUAW*-
nrrtv L*ou*9Piiecto, 0
RL/RJT:rjt
Department of
Environmental Quality
Amanda Smith
Execulive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Direclor
MEMORANDLM
CARY R. HERBERT
Governor
CREC BELL
Lieutenanl Governor
TO:
Through:
FROM:
DATE:
File
Phil Goble, Section Manager
Russell J. Topham, P.E.
November 6,2012
,//",,PBO
SLIBJECT: Sulfuric Acid Release: Review of Response to DRC Letter of August 30, 2012 Re:
Additional Excavation Volume at Former Claricone Site, Energy Fuels Resources (EFR)
Uranium Mill at White Mesa, near Blanding, Utah
On October 29,2012, the DRC received a letter from EFR bearing the subject line Response to Utoh
Divisioin of Radiation Control (" DRC ") letter of August 30, 201 2 Report Justifying Additional Volume o.f
Excavationfor Claricone (Response). The following details the results of my review of the Response
document.
1.0 Findings and Recommendations
EFR has complied with the time line imposed to submit the Response. The financial aspects of the
Response appear adequate. The plan requires refinement, including the following data:
l. To facilitate positive identification of the excavation boundary, EFR would need to provide either
coordinates tied to USGS survey monumentation or a boundary description tied to USGS survey
monuments.
2. The plan does not address contamination extending beyond the intended limits of excavation,
should such occur. The additional volume would probably suffice, but the plan should at least
address the possibility that contamination may extend beyond the designed excavation boundaries,
EFR should include this consideration in its justification.
3. ln conjunction with coordinates or a boundary description, the elevation of the bottom of the
excavation in feet above mean sea level will provide sufficient control. This elevation reading
should reference USGS survey monumentation.
2.0 History
On April 12,2012, EFR personnel noticed a release of solution from the Claricone process unit at the
White Mesa Uranium Mill. The solution had saturated the soil and filled the service tunnel at the base of
195 North 1950 West . Salt take City, UT
Mailing Address: P.O. Box 144850 . Salr take City, UT 841 l4-4850
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364414
www.deq.utah.gov
Printed on I 00% recycled paper
Page2
the Claricone. Constituents of concern in the solution included sulfuric acid and dissolved uranium, Upon
detection of the release, EFR personnel notified the DRC by telephone, and began transferring all
recoverable fluid to Roberts Pond. I happened to have an inspection at the mill scheduled for April 13ft, so
I was able to observe conditions at the Claricone site the moming of April l3n before retuming to the
office. By the time of my observations, free fluid had been transferred to Roberts Pond. EFR commenced
excavating soil from the release site prior to my departure on April l3n.
EFR provided the DRC a Written Notice and Response Plan dated May 4,2012 (the Plan). The PIan
essentially detailed actions already taken, as EFR had completed the cleanup by April 27ft. The DRC
performed a storm water inspection at the mill on June 2l , 2012, and included the findings of its review of
the Plan with the inspection report on August 30,2012 (the Plan Review). Noting that EFR had approached
the cleanup in a different manner than the DRC would have preferred, the DRC included in the Plan
Review a requirement for EFR either to design an investigative study to provide assurance that EFR had
successfully removed impacted soils and fluid, or to design an over excavation sufficient to capture any
additional contamination that may remain.
In a letter to the DRC on September 7,2072, EFR committed to design an over excavation and to provide a
report detailing justification for the excavation design. EFR would include in the report five elements:
l. Calculated volume of the over excavation;
2. Justification of the design as adequate to assure removal of impacted soils;
3. A surface map of the mill site;
4. Cross-sections through the excavation; and,
5. A detailed opinion of probable costs (cost estimate) for surety purposes.
EFR drafted the Response to meet these requirements. The DRC received the Response on October 29,
2012, meeting the time line the DRC imposed on EFR to prepare the Response.
3.0 Results of Review
EFR provided in its Response all five elements listed above. However, I have concerns about the design as
presented.
L Viewed through the lens of surety, the DRC must be able to execute the over excavation absent
input from EFR personnel. For DRC confidently to remove the identified soil, the DRC must have
means to identify on the ground the boundary of the excavation. The surface map lacks sufficient
detail positively to identiff the intended limits of excavation. To facilitate positive identification of
the excavation boundary, EFR would need to provide either coordinates tied to USGS surney
monumentation or a boundary description tied to USGS survey monuments. Given that structures
and other landmarks will be demolished prior to bringing heavy equipment in to perform this
excavation, dimensioning to known, permanent fixed site features such as building corners will not
provide usefu I information.
The engineer's opinion of probable cost seems reasonable. Quantities appear appropriate for the
work contemplated, and the unit costs reflect values used in the recently-approved surety
calculation.
Page 3
2.
3.
The planned over excavation relies on removal of two feet of soil in all lateral directions from, and
below the limits of the excavation already performed. The plan makes no provision for "chasing"
any contamination found during execution of the work. EFR estimated the volume of the resulting
excavation to the limits of the design, and noted the difference between that volume and the
volume of the original excavation. Noting that any contamination in the additional two feet to be
excavated may impact a portion of the clean fill, EFR provided for replacement of such
contamination by tripling the volume difference previously calculated when assembling the cost
estimate. The plan does not address contamination extending beyond the intended limits of
excavation, should such occur. The additional volurne would probably sffice, but the plan should
at least address the possibility that contamination mqy extend beyond the designed excavation
boundaries. EFR should include this consideration in its justification.
The cross-sections do not appear on the drawing. EFR relies on a written description to convey the
information normally found in cross-sections. While not a fatal flaw, this is not typical engineering
practice. In conjunction with coordinates or a boundary description, the elevation of the bottom of
the excavation in feet above mean sea level will provide sfficient control. This elevation reading
should reference USGS survey monumentation.